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Contents

Official guidance
Corporate Finance Manual

CFM72000 · Other tax rules on corporate finance: securitisation

  • CFM72010 · Background
  • CFM72020 · Background: basic terminology
  • CFM72030 · Background: true sale/asset-backed securitisation
  • CFM72040 · Background: true sale/asset-backed securitisation: example
  • CFM72050 · Background: master trust securitisation
  • CFM72060 · Background: master trust securitisation: example
  • CFM72070 · Background: whole business and other types of securitisation
  • CFM72080 · Background: synthetic securitisation: example
  • CFM72090 · Background: SPVs and other common features
  • CFM72100 · Periods beginning before 1 January 2005
  • CFM72110 · Periods beginning before 1 January 2005: general points
  • CFM72120 · Periods beginning before 1 January 2005: bad and doubtful debts
  • CFM72130 · Periods beginning before 1 January 2005: offshore SPVs
  • CFM72140 · Periods beginning before 1 January 2005: example
  • CFM72200 · Periods beginning on or after 1 January 2005: overview of the new rules
  • CFM72210 · Periods beginning on or after 1 January 2005: the interim regime
  • CFM72220 · Periods beginning on or after 1 January 2005: the interim regime: definitions
  • CFM72230 · Periods beginning on or after 1 January 2005: the interim regime: the note-issuing company
  • CFM72240 · Periods beginning on or after 1 January 2005: the interim regime: other types of securitisation company
  • CFM72250 · Periods beginning on or after 1 January 2005: the interim regime: application of former UK GAAP
  • CFM72260 · Periods beginning on or after 1 January 2005: the interim regime: continuation after 2008
  • CFM72270 · Periods beginning on or after 1 January 2005: the interim regime: continuation after 2008: transitional rules
  • CFM72300 · Periods beginning on or after 1 January 2007: the permanent regime
  • CFM72310 · Periods beginning on or after 1 January 2007: ‘alternative finance’ arrangements
  • CFM72320 · Periods beginning on or after 1 January 2007: the regulations
  • CFM72330 · Periods beginning on or after 1 January 2007: the regulations: commencement
  • CFM72340 · Periods beginning on or after 1 January 2007: the regulations: interpretation
  • CFM72350 · Periods beginning on or after 1 January 2007: the regulations: interpretation: ‘financial assets’
  • CFM72360 · Periods beginning on or after 1 January 2007: the regulations: scope
  • CFM72370 · Periods beginning on or after 1 January 2007: the regulations: meaning of a ‘securitisation company’
  • CFM72380 · Periods beginning on or after 1 January 2007: the regulations: the note-issuing company
  • CFM72390 · Periods beginning on or after 1 January 2007: the regulations: the note-issuing company: ‘independent persons’
  • CFM72400 · Periods beginning on or after 1 January 2007: the regulations: the note-issuing company: incidental activities
  • CFM72410 · Periods beginning on or after 1 January 2007: the regulations: the asset-holding company
  • CFM72420 · Periods beginning on or after 1 January 2007: the regulations: the asset-holding company: partnerships
  • CFM72430 · Periods beginning on or after 1 January 2007: the regulations: the asset-holding company: subordinated debt
  • CFM72440 · Periods beginning on or after 1 January 2007: the regulations: intermediate borrowing companies
  • CFM72450 · Periods beginning on or after 1 January 2007: the regulations: warehouse companies
  • CFM72460 · Periods beginning on or after 1 January 2007: the regulations: warehouse companies: abortive warehouse arrangements
  • CFM72470 · Periods beginning on or after 1 January 2007: the regulations: commercial paper funded companies
  • CFM72480 · Periods beginning on or after 1 January 2007: the regulations: ‘retained profit’
  • CFM72490 · Periods beginning on or after 1 January 2007: the regulations: ‘retained profit’: dividends received
  • CFM72500 · Periods beginning on or after 1 January 2007: the regulations: conditions to be met by securitisation companies
  • CFM72510 · Periods beginning on or after 1 January 2007: the regulations: the payments condition: introduction
  • CFM72520 · Periods beginning on or after 1 January 2007: the regulations: the payments condition: the formula
  • CFM72530 · Periods beginning on or after 1 January 2007: the regulations: the payments condition: examples of ‘RA’
  • CFM72540 · Periods beginning on or after 1 January 2007: the payments condition: meaning of payment
  • CFM72550 · Periods beginning on or after 1 January 2007: the payments condition: failure to make a payment
  • CFM72560 · Periods beginning on or after 1 January 2007: the payments condition: other points
  • CFM72570 · Periods beginning on or after 1 January 2007: the unallowable purposes rule
  • CFM72580 · Periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: the formula: ‘RP’ and ‘DS’
  • CFM72590 · Periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: the formula: ‘D’
  • CFM72600 · Periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: the ‘specified amount’
  • CFM72610 · Periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: applies instead of the normal CT rules
  • CFM72620 · Periods beginning on or after 1 January 2007: modifications to commencement and cessation rules
  • CFM72630 · Periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules
  • CFM72640 · Periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: group relief
  • CFM72650 · Periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: capital assets
  • CFM72660 · Periods beginning on or after 1 January 2007: the regulations: modifications to certain tax rules: loan relationships
  • CFM72670 · Periods beginning on or after 1 January 2007: the regulations: modifications to certain tax rules: derivative contracts
  • CFM72675 · Periods beginning on or after 1 January 2018: the regulations: modifications to certain tax rules: recovery of unpaid corporation tax
  • CFM72680 · Periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: other points
  • CFM72690 · Periods beginning on or after 1 January 2007: credit card securitisations
  • CFM72700 · Periods beginning on or after 1 January 2007: modifications to other tax rules: taxation of the investor
  • CFM72710 · Periods beginning on or after 1 January 2007: other types of securitisation company
  1. Other tax rules on corporate finance: securitisation: contents
  2. Other tax rules on corporate finance: securitisation: background: synthetic securitisation: example

CFM72080 | Other tax rules on corporate finance: securitisation: background: synthetic securitisation: example

From HM Revenue & Customs · Corporate Finance Manual

Synthetic securitisation

Diagram of a synthetic securitisation

Text Alternative

A synthetic structure is used where no assets are sold by the originator.

A charitable trust is formed that owns the equity in an issuer SPV.

The originator enters into a credit default swap with the issuer SPV. For example, the originator pays premiums to the issuer SPV and in return receives protection against future default from the issuer SPV.

The issuer SPV sells securities (offering interest and principal) along with credit derivative premiums to third party investors and credit derivative counter-parties.

The proceeds from third party investors and credit derivative counter-parties from the sale of the securities and credit derivative premiums are paid to the issuer SPV.

The proceeds from the sale of securities are deposited by the issuer SPV with a collateral provider, in return for which the collateral provider pays interest to the issuer SPV. The principal deposited with the collateral provider is used to fund payments due to the originator by the SPV under the credit default swap and any remaining collateral is returned as principal on repayment of the securities.

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